FAQ  Whistleblowing



What can be reported?
The employee or associate can report any conduct related to:

  •  notable incidents of which they have become aware, and regarding which they have details concerning possible unlawful activity, fraud or corruption
  • documented instances of non-compliance with the procedures, Model 231, the Italian Code of Ethics or conduct attributable to possible commissions of crimes pursuant to the articles of Italian Legislative Decree no. 231/2001
  • sufficiently detailed and documented episodes, even where not all the details are complete, which could lead to the hypothesis of "maladministration" and/or related to phenomena that may involve risks for the company

What are the protections for the reporting person
Any employee who, in the interest of the integrity of the Company, reports unlawful conduct of which they have become aware on the basis of their employment relationship cannot be sanctioned, demoted, dismissed, transferred, or subjected to any other organisational measure with direct or indirect negative effects on their working conditions as a result of the report. If the Company applies retaliation measures against the reporting party, the latter may notify the ANAC (Italian National Anti-Corruption Authority).
The ANAC informs the Department of Public Service of the Presidency of the Council of Ministers, or the other guarantee or disciplinary institutions, in relation to the activities and any relevant measures.
In addition, the company must provide, in its disciplinary system, for the application of penalties against any parties who violate the protective measures pertaining to the reporting party.

Are anonymous reports allowed?
The Whistleblowing model admits both nominative and anonymous reports, and the ENAV platform allows both reporting modalities.

Are "anonymous reports" actually anonymous?
The user makes the report using credentials generated by the system itself and which are not linked to the network account. It is not possible to trace the user who makes a report without the use of illegal network traffic interception tools which are not accessible to any user and, in any case, must be operated during the user's connection to the portal

Who receives the reports?
 The reports are received by the Internal Audit Department – Corporate Compliance – Anticorruption, Fraud and Whistleblowing.  Periodically and on a yearly basis, the Internal Audit Department draws up a report for the Committee for Control and Risks and for Related Parties, the Board of Directors, and the Board of Statutory Auditors on the whistleblowing reports received and on the progress of the verification activities. Similarly, a report is drawn up for the Supervisory Body on all reports with impacts that are only marginal in relation to the Code of Ethics and the Organisational Model pursuant to Italian Legislative Decree 231/01.